The old landfill is
leaching 1,4-dioxane, a known
landfill-associated carcinogenic contaminant (pages 4 and 8 of
the
report)

1,4-dioxane above
the drinking water standard was
detected
within the “DEP Approved Wellhead Protection Area (Zone II)”
(page
9)

The Town
selectively
analyzes the data to argue that “significant contamination” has not
been observed (page 4)

There is "a likely
connection between the landfill and drinking water resources"
and "potential bedrock contamination
originating from the landfill, which
requires further investigation with additional bedrock wells." (page 10)

SunEdison,
the company selected by the Town of Amherst to install solar arrays on
the town's landfills, looses almost
90% of its stock value and has a class action lawsuit filed
against it for the failure to
disclose its unsustainable level of debt and unsustainable business
model. Click here to
read more.

The Town of Amherst was in the press just recently
for a much smaller water quality
problem that took a fine and three years to correct. Click here to read more.

We have a much bigger problem than just solar on a
substandard landfill cap.Are we waiting for Amherst to become a second Flint,
Michigan?

According to the letter
from the
Massachusetts DEP, the KC Trail
conditions depicted on the pictures
below are the result of "stripping of naturally occurring iron
and manganese
from the soils due to the organic loading of the former landfill. ...
The only parameter above any standard was arsenic in certain sediment
locations ... and a quantitative risk assessment for the presence of
the arsenic ... was shown to pose no significant risk to human health."

According to the Second Roux Associates
Report:

"the
risk associated
with certain contaminants has not been addressed at all.
Specifically, the risk posed by 1,4-dioxane to human health and the
environment is unknown because 1,4-dioxane was not identified as a
“contaminant of concern” and was therefore not considered when the
human health and ecological risk assessments were conducted for the
landfill and surrounding wetlands. The omission of 1,4-dioxane in the
human health and ecological risk assessments is likely due to the high
detection limits utilized by the Town and subsequent ignorance of the
prolific nature of 1,4-dioxane originating from the landfill."

Click
on
pictures
to
see
a
bigger
image

1,4-dioxane
was
detected in the monitoring well in the Zone II
Aquifer Protection Area in the concentrations substantially (~50 times)
exceeding the drinking water standard: "In short, the
water in MW 4-08 is
considered drinking water and the measurement of 1,4-dioxane at 14.4
μg/L constitutes a condition that must be reported to MassDEP and
handled under the MCP." (page 9)

"The source of
this “significant contamination” may be attributable to drums
historically buried at the landfill: Sometime prior to
approximately 1980 up to 50 drums with content described variously as
“paint,” “oil-based paint,” “most likely paint,” and “chemical waste”
were buried at the landfill over 50 feet below ground surface." (page 8)

There is "a
likely connection between the landfill and drinking water resources...
The
presence
of
1,4-dioxane
in
both
MW
4-08
and
MW
5-08
indicates
potential
bedrock
contamination
originating
from the landfill, which
requires further investigation with additional bedrock wells." (page 10)

It increasingly appears that the Old Landfill's abutters were just a canary in a mine
that discovered the much bigger problems of the
landfill leachate entering the Amherst's drinking water aquifer,
described in the Roux report. To protect our drinking water supply,
we
have
to
push
the
Town
acknowledge
the
problem,
start
monitoring
the
dioxane contaminant as suggested in the report and plan steps for proper
remediation.

The Problem:
The
old landfill's cap is deteriorating and leaking contaminants into the
surrounding wetlands. The landfill was
never
properly
capped: the 1985-1987 closure of the landfill violated the
requirements
of the 1985 DEP Closure Permit. Recent test data from 2007 and 2010 DEP reports show that the cap further
deteriorated and is currently leaking as
much as 940
gallons/acre/day of leachate that
enters the groundwater. The contamination
has already spread
to conservation wetlands
as far as half a mile away from it, which are located in the primary aquifer recharge area.

NEW:
Independent
Environmental
Evaluation
of
the
Old
Landfill
Site:
Area Group engaged Roux
Associates to perform an independent environmental evaluation
of the Old Landfill and its suitability for hosting a large solar
array. The evaluation not only confirmed our concerns, but also found
that site closure was even more sub-standard (6 inches of clay) than
the already reduced depth of 8 inches. This is just 50% of the
12"
clay depth required by the 1985 standards, and 33% of the
18" clay depth required today. The research has found that the site is
letting 150 times more water in than was allowed by the original DEP
design, and 1500 times more than it is allowed by today's landfill
capping standards. The study concludes that:

The landfill's assessment and capping is incomplete

The landfill is poorly maintained

The recent regrading did not address the problems
of the substandard clay cap

The landfill is an uncontrolled
source
of
pollution
to
the
environment

Using the site for a
large solar array is in a direct
contradiction with The Guide to Developing Solar Photovoltaics
at Massachusetts Landfillsdocument issued by
Massachusetts Department of Energy Resources.

NEW:
Analysis of the DEP Annual Site Monitoring Data uncovers an even more
disturbing picture: When the Town rejected the conclusions of
the report (click here
to read the Town's
response) without backing them with factual data, Roux Associates
analyzed the Town's response and rebutted all of the
Town's assertions based on factual scientific data.

In addition, Roux Associates analyzed sampling data from the DEP annual
site monitoring reports. The results
presented an even more
disturbing picture of the current condition of the landfill site and
its cap, confirming our worries:

1,4-dioxane,
a known carcinogenic contaminant,
leaking in the Zone II aquifer protection area (pages 4, 8 and
9 of the
report)

the Town undercounts the
number of
drinking water standard exceedances in the
groundwater, 5 instead of at least 27 (page 4)

The risk posed by
1,4-dioxane to human health and
the
environment is unknown because 1,4-dioxane was not identified as a
“contaminant of concern” and was therefore not considered when the risk
assessments were conducted for the landfill (page 6)

The Town selectively
selectively
analyzes the data to argue that “significant contamination” has
not
been observed (page 4)

The landfill maintenance
is sub-standard (page 7), and “Significant
contamination”
has
already
been
observed, demonstrating that the landfill cap is
not
effective in its current state (page 3, 5 and 6)

The effects of additional stress of a solar array on a
landfill
like the Old Amherst landfill are highly uncertain. It is likely that
installation of a solar array on the landfill in its current state will
substantially intensify the amount of contamination discharging from
the landfill and pose a risk to public health, safety, and the
environment (page 11). In addition, such an installation will significantly increase the
future remediation costs and may limit the
future remedial options (page 12).

The Projects:
An original project proposed by the Blue Wave Capital, LLC planed
covering 30+ acres of the site
with an industrial solar installation with 20,000 panels, with 4.75 MW
peak power, but a meager 0.6 MW
average output throughout the day. Installing a huge solar array
on a deteriorated landfill cap with settlement problems presents enormous
environmental risks. The original project was cancelled, and a
new project by Sun Edison is now in the planning stages. The new
project targets both the new and the old landfills, with 2.8 MW being
planned for the old landfill installation.

Questions:The
group questions the
wisdom of a such installation compared with alternative solutions that
install solar panels on the roofs of
municipal and school buildings that would directly benefit the town without
endangering the environment.
Roof installations would allow the town to use generated
electricity right at the source, instead of selling it to the grid and
then repurchasing it with the delivery surcharge added.

It
will
be
impossible
or
prohibitively
expensive
to
fix
the
landfill's
cap
if
20,000+
solar
panels are
installed on top of it, and the contamination by the leaking leachate
will continue for
the next 30 years, causing a wide range of environmental problems.

Legal Issues:
The
project is in violation
of the State Grant the town used for capping the landfill. The
State Grant Agreement required
the
town
to
preserve
the
site
for
recreational
use and record
a Deed Restriction for
recreational use of the site. The State Grant also required the Town to
cap the site according to the specifications of the DEP Closure Permit,
which were never satisfied. Click here on
information about the actions taken by the group.

Actions:AREA retained a
local attorney who is
an expert on zoning and land-use, and set up a Trust Fund for all
contributions to the group's mission. Click here
for information about the recent actions.

Click here for more information on the
current condition of the old landfill site.

Click
on
pictures
to
see
a
bigger
image

The
first block of
pictures was taken just recently, in March of 2016. Compare them with
the rest of the pictures below that were taken before the recent
regrading.

According to the Roux Associate
Summary Report (page 3), "regrading
does
not
modify
the
contour
of
the
cap
or
further
increase
the
cap
thickness.
Instead,
water that was
once visible surface water will still be present, but will exist below
the surface of the regraded areas. This water is still available
to infiltrate the thin, permeable cap."

The pictures shown
below were taken before the regrading.

Settlement and
Water Ponding Problems in the middle areaA big portion of this
water will seep into the landfill, get contaminated and enter ground
water.

According to the 2007
DEP report, the "impermeable" clay cap is leaking 150 times more than allowed by the
original Closure Permit. 940
gallons/acre/day of leachate are produced by precipitation
infiltrating through the existing landfill cap. Click
here for more information.

Problems near
the circular access roadThe planned regrading
does not address the condition of the clay cap:
it simply adds more soil on top. The cap already has 24 inches of soil
on top of it, and adding more will not restore impermeability of the
clay layer. Alternative remediation
methods must be explored.

Problems near
residential homesUnlike the Pittsfield Brownfield,
a former leveled industrial ground with compacted soil, the Amherst
landfill
ground is soft and sagging, a bad fit for supporting a huge solar array
with heavy inverters, transformers and concrete ballast beams to
support each of the 20,000+
panels.

Problems near
the entrance (Northern area)
It will be
impossible to monitor and fix developing problems as they occur if the
landfill is
covered with thousands of solar panels. The current leakage problem must be addressed
before contemplating any additional
load on top of the already deteriorating cap.

The
landfill is a giant sponge soaked
with toxic chemicals. Because it is unlined, these contaminants
are slowly leaching out of the landfill into the ground water. The
combined weight of thousands of tons of industrial equipment will push
the cap down, squeezing the sponge.
This
will
accelerate
the
leaching
process,
threatening
the
Town's
drinking
water supply.

Problems in the
Southern AreaThere is no data on the long-term effect
of
placing such a big load on the landfill cap. When the cap cracks,
it will unleash an environmental disaster that will negate any
projected financial and environmental benefits of the project.

Tracks
from equipment used to drill monitoring wells
The landfill leachate enters
groundwaters and contaminates surrounding environment. The
wetlands of the Hop Brook Drive
(located just 100 yards away from the Lawrence Swamp Water Protection
Area for the Town's drinking water
wells) and Gull Pond
(located off the Old Farm Road) already have concentrations of contaminants
exceeding WQC and MassDEP groundwater standards and SSC sediment
guidelines. Urgent actions are required to prevent further
contamination.

Contaminated water
seeping through the ground

Street
sweepings left from the
dumped snow

The
capital investment company will subcontract all work and will be long
gone by the time the landfill develops caps problems, which will leave
the Town footing the bill.